It is our policy to comply with global AML laws and consequently, we only conduct business with
verified clients who conduct legitimate business activity and whose funds are derived from legitimate
Notwithstanding the aforesaid, Koinexpert, where considered to be an “accountable institution”,
strictly adheres the obligations placed upon it under the Act. This specifically includes the obligations
as set out in Chapter 3 thereof in respect of AML measures and the Financial Intelligence Centre of
South Africa (hereinafter, “FICA”).
In respect of the aforesaid, Koinexpert specifically reserves its rights to compile Suspicious Activity
Reports (hereinafter, “SAR’s”) comprised of user and transaction information in respect of all
transactions, and furnish said SAR’s to FICA as set out in Part 3 of Chapter 3. Accordingly, the following
reporting mechanisms shall be in place: -
Cash transactions with a value higher than R 25 000.00 (Twenty-five thousand rand), will be
reported to FICA as soon as Koinexpert becomes aware thereof, alternatively, within 2 (two) days
from the date of such transaction, as per Section 28 of the Act;
Transactions which have been identified as pertaining to property associated with terrorist and
related activities as defined under the Act, will be reported to FICA as soon as Koinexpert becomes
aware thereof, alternatively, within 2 (two) days from the date of such transaction, as per Section
28A of the Act;
Transactions which have been received or are soon to be received, and which have been identified
or reasonably suspected to be proceeds of unlawful activities or property which may be connected
to an offence relating to the financing of terrorist and related activities, will be reported to FICA as
soon as Koinexpert becomes aware thereof, alternatively, within 15 (fifteen) days from the date of
such transaction, as per Section 29 of the Act. For purposes of the aforesaid, Koinexpert will
specifically report activities of the following nature , namely: -
facilitating the transfer of proceeds of unlawful activities;
facilitating the transfer of property connected to the financing of terrorist and related activities;
if the transaction has no apparent business or lawful purpose;
if it is to avoid any duty to report in terms of FICA;
the evasion of tax, duties and levies administered by the South African Revenue Service
(hereinafter, “SARS”); and
the financing of terrorist and related activities.
Transactions, whether cash or otherwise, which involve the ingress and/or egress of funds with a
value higher than R 25 000.00 (twenty-five thousand rand) to or from the Republic of South Africa,
will be reported to FICA as soon as Koinexpert becomes aware thereof, alternatively, upon demand
by FICA, as per Sections 30 and 31 of the Act (the aforesaid will be operative as from the date upon
which the aforesaid Sections’ commencement is proclaimed).
In respect of the aforesaid, Koinexpert strictly reserves its rights not to disclose any information
regarding the reporting of the aforesaid, either to the party being reported or otherwise.
Employees of Koinexpert are obliged to read and follow this Policy and if a known or suspected
breach of this policy is identified, it is the duty of employees to report it to a senior staff
member immediately or failing that, to one of the directors of the company or by sending an email
directly to: legal@Koinexpert.com., alternatively, flagging the breach to the AML Officer.
All reported breaches and incidents will be reviewed and, if deemed necessary, will be
reported to the relevant authorities. If the authorities should seek further information related
to the incident or breach, Koinexpert and its staff will provide complete cooperation and
assistance to authorities as needed.
Employees must not notify anyone involved in a suspicious transaction that it has been flagged
and no further steps must be taken until instructions have been provided to an employee by a
senior staff member.